You have a right to know about the proposed Settlement in this class action lawsuit and about your rights and options before the Court decides whether to approve the Settlement.

The Court in charge of this case is the United States District Court for the Eastern District of Virginia. The case is called Jane Doe, et al. v. MasterCorp, Inc., Case No. 1:24-cv-00678. The Settlement is between Jane Doe, John Doe 1, and John Doe 2 (collectively “Plaintiffs”), on behalf of the proposed Settlement Class, and MasterCorp., Inc. (“MasterCorp” or “Defendant”).

Plaintiffs claim that MasterCorp subjected Settlement Class Members to wrongful labor and immigration-related wrongful conduct in violation of 18 U.S. Code sections 1581 et seq. (“TVPRA”); failed to pay the workers all compensation due to them in violation of 29 U.S. Code sections 201 et seq. (“FLSA”) and the wage and hour laws of various states; engaged in discrimination on the basis of national origin in violation of federal and state anti-discrimination statutes; and committed common law fraud and negligence. The major claims in this lawsuit for which Plaintiffs are seeking relief on an individual and class basis are their claims asserting violations of TVPRA, discrimination on the basis of national origin, and their common law claims.

In a class action, one or more people called Plaintiffs sue on behalf of people who have similar claims. All these people are a class or class members.

MasterCorp denies it has committed any wrongdoing or violated any state or federal law pertaining to wrongful labor or immigration-related wrongful conduct, payment of wages, hours of work, or earnings in any form, or discrimination on the basis of national origin. The Court has not decided who is right or wrong. Instead, the parties have agreed to the Settlement to avoid the risks, uncertainty, expense, and burden of further litigation. Plaintiffs and their attorneys think the Settlement is in the best interest of the Settlement Class and is fair, reasonable, and adequate.

The Settlement Class includes all workers who are Colombian Nationals or of Colombian origin who were paid by Perennial Pete, LLC or one of its affiliated entities or companies, and who provided housekeeping services at resorts in the United States where MasterCorp was responsible for housekeeping services between March 19, 2021 and May 15, 2024.

If you are not sure whether you are a Settlement Class Member, or have any other questions about the Settlement, you can email the Settlement Administrator at info@ColombianHousekeeperSettlement.com or call toll-free from the U.S. at 1-888-825-1238 or from Colombia at 01-800-519-1529.

Yes. You can still participate, the claim filing deadline passed on November 01, 2024, but you can still submit a late claim form by emailing info@ColombianHousekeeperSettlement.com.

The Settlement was approved by the Court, which required MasterCorp will pay a Settlement Amount of $4,950,000 in U.S. dollars for:

1. Payments to Settlement Class Members who file a valid and timely claim;
2. Attorneys’ fees and reasonable costs to Class Counsel (not to exceed one third of the Settlement Amount plus their reasonable costs);
3. Service awards to Plaintiffs (maximum amount of $7,500 in U.S. dollars each);
4. Settlement administration and notice costs to the Settlement Administrator; and
5. Any applicable taxes.

Payments were distributed equally among all Settlement Class Members who file a valid and timely claim.

Settlement Class Members who file a valid and timely claim will receive an equal share of the NET Settlement Amount. The NET Settlement Amount is the $4,950,000 Settlement Amount less attorneys’ fees and reasonable costs, service awards, settlement administration costs, and any applicable taxes.

There are an estimated 205 Settlement Class Members. If all 205 file a claim, they will each receive 1/205 of the Net Settlement Amount. If fewer Class Members file a claim, payments will increase equally on a pro rata share. For example, if only 125 Settlement Class Members file a claim, each will receive 1/125 of the Net Settlement Amount. However, there is a cap. The maximum payment any Settlement Class Member can get is 5/205 of the Net Settlement Amount. Any remaining funds in the NET Settlement Amount will be distributed to St. Jude for undocumented-immigrant-related services.

To be eligible to receive a payment from the Settlement, you must complete and submit a timely Claim Form. You can can download a Claim Form from the Important Documents page, or write to the Settlement Administrator at the address below to request a copy of the Claim Form be mailed or emailed to you:

Colombian Housekeeper Settlement
c/o JND Legal Administration
PO Box 91308
Seattle, WA 98111

info@ColombianHousekeeperSettlement.com

If you do not submit a valid Claim Form by November 01, 2024, you will not receive a payment, but you will be bound by the Court’s judgment. If you submit a claim after November 1, 2024 your claim will be deemed late and you will not receive the same amount as those who filed a timely claim.

Payments were sent to Settlement Class Members who submitted a valid and timely claim on December 31, 2024.

If you are a Settlement Class Member, unless you exclude yourself from the Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against MasterCorp about the claims released in this Settlement. It also means that all the decisions by the Court will bind you. The Released Claims and Releasees are defined in the Settlement Agreement and describe the legal claims that you give up if you stay in the Settlement. The Settlement Agreement is available on the Important Documents page.

The deadline to exclude yourself passed on November 01, 2024.

No. Unless you exclude yourself, you give up any right to sue MasterCorp for the claims that the Settlement resolves. The deadline to exclude yourself passed on November 01, 2024.

No. You will not get money from the Settlement if you exclude yourself. If you exclude yourself from the Settlement, do not send in a Claim Form asking for benefits form the Settlement.

No. The Court has appointed Rachel Geman from Lieff, Cabraser, Heimann & Bernstein, LLP and Mark Hanna from Murphy Anderson PLLC as Class Counsel. You will not be charged for these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel filed a motion seeking attorney's fees for $1,650,000 and litigation costs of $22,246. They also requested a service award of $7,500 for each Class Representative. Information regarding this motion can be found on the Important Documents page. The Court granted the motion on November 22, 2024.

The deadline to object passed on November 01, 2024.

Objecting is simply telling the Court that you don’t like something about the Settlement. You can object to the Settlement only if you do not exclude yourself from the Settlement. Excluding yourself from the Settlement is telling the Court that you don’t want to be part of the Settlement. If you exclude yourself from the Settlement, you have no basis to object to the Settlement because it no longer affects you.

The Final Approval Hearing was held on November 22, 2024 at 10:00 a.m. ET at the United States District Court for the Eastern District of Virginia, Albert V. Bryan U.S. Courthouse, 401 Courthouse Square, Alexandria, VA 22314. The settlement was approved during this hearing. 

No. The Final Approval Hearing occurred November 22, 2024. Class Counsel answered any questions that the Court had.  

Yes. You may have asked the Court for permission to speak at the Final Approval Hearing. A “Notice of Intention to Appear.” must have been filed with the Court by November 01, 2024, to do so.

If you do nothing, you will not get a payment from the Settlement. Unless you exclude yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against MasterCorp about the legal issues in this case, ever again.

The notice summarizes the proposed Settlement. You can visit the Important Documents page to review the complete settlement documents, papers, and pleadings filed in this litigation, or contact the Settlement Administrator for more information:

Colombian Housekeeper Settlement
c/o JND Legal Administration
PO Box 91308
Seattle WA 98111

1-888-825-1238 (from U.S.)
01-800-519-1529 (from Colombia)

• The Settlement Administrator is required to maintain Class Member information as confidential.
• Whether or not you are documented to work in the United States, you are still entitled to recover your settlement share (provided you make a timely and accurate claim). In other words: you do not have to be a U.S. citizen or legal resident to qualify for payment. 
• Although the Claim Form asks for the name of the person who recruited/hired you and the name of your manager, you do not have to identify them if you do not want to.
• Overall: Although no guarantees can be provided and this is not immigration advice, we want to stress that the process to file is designed to protect your privacy and was designed with knowledge of the workers’ circumstances. A U.S. Court (a judge) has given preliminary approval to this process. We do not believe there is any realistic legal risk or effect on immigration status that will be caused by filing a claim.
• Final point: Some of your fellow workers have spoken with Class Counsel (the lawyers representing the workers) and the lawyers are always available. You can email Class Counsel at rgeman@lchb.com or call Class Counsel at 800-949-0585.